Our trading policy sets out internal guidance and rules on the proper handling of inside information and for trading in the Company’s securities. In addition, our disclosure policy defines the information requirements and responsibilities with regard to informing the public in a fair and transparent manner, and at the earliest possible stage, about significant developments and changes concerning PolyPeptide.

We have introduced ordinary blocked periods, during which time the Company and blocked persons must not deal in Company securities or make respective recommendations to any other person regardless of whether or not such person is in possession of inside information. During the course of 2024, the Board of Directors brought forward the start of the ordinary blocked periods from 31 December and 30 June to 15 November and 15 May, respectively. Thus, PolyPeptide’s ordinary blocked periods are (i) from 15 November until the lapse of one trading day following the public release of our annual results and (ii) from 15 May until the lapse of one trading day following the public release of our half-year results.

Blocked persons subject to the ordinary blocked periods include members of the Board of Directors, the Executive Committee, the PolyPeptide Management Committee and other individuals having access to inside information during these periods as identified by the CFO and General Counsel, in consultation with other members of management. The General Counsel maintains a list of the blocked persons, which is reviewed together with the CFO ahead of the commencement of each ordinary blocked period, and informs such individuals (other than members of the Board of Directors or the Executive Committee and the PolyPeptide Management Committee, who are ex officio blocked persons), of their designation as a blocked person. Each blocked person must also deliver an acknowledgment of their designation as a blocked person to the General Counsel. In addition, the General Counsel reminds all blocked persons by e-mail of the applicable restrictions ahead of each ordinary blackout period.

In 2024, the following ordinary blocked periods applied: from 31 December 2023 until (and including) 12 March 2024; from 15 May 2024 until (and including) 13 August 2024; and from 15 November 2024 until (and including) 11 March 2025. No exceptions to the ordinary blocked period were granted in 2024.

In addition to ordinary blocked periods, the Chair, CEO, CFO or the General Counsel may each impose extraordinary blocked periods from time to time where they consider it necessary or appropriate, including (without limitation) where inside information exists or may arise (for example in connection with a potential material transaction) or where restrictions are required or appropriate to comply with regulatory or other requirements.